In the case of Fitzgerald, Public Administrator v. United States Lines Co., 1962, the Supreme Court ruled on a dispute regarding compensation for wrongful death under maritime law. The plaintiff was seeking damages for the death of a longshoreman who died while working aboard one of defendant's ships in New York Harbor. The issue at hand was whether or not punitive damages could be awarded under general maritime law in cases where negligence resulted in death. In its decision, the court held that there is no provision for punitive damages within general maritime law and therefore they cannot be awarded even if negligence led to someone’s demise. This ruling clarified an important aspect of liability and compensation rules within U.S marine legislation.

In the dissenting opinion for Fitzgerald, Public Administrator v. United States Lines Co., Justice Harlan argued that the majority's decision to allow a wrongful death action under New York law was inconsistent with prior Supreme Court decisions and federal maritime law. He contended that this ruling effectively allowed state laws to override federal statutes in matters of admiralty jurisdiction, which he believed was not permissible under the Constitution or established legal precedent. Furthermore, Justice Harlan expressed concern about potential confusion and inconsistency resulting from different states applying their own laws in similar cases involving maritime accidents. He also disagreed with the majority's interpretation of certain provisions of Death on High Seas Act (DOHSA), arguing they were intended to provide uniformity across all jurisdictions rather than allowing individual states' laws to apply.